eobr defined - mys · 2014-01-31 · circuit to invalidate 2010 final rule. • in august 2011, the...

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EOBR Defined

Success, Challenges and

Embracing the Change


Session Learning Objectives

1. Understand FMCSA Rules and Update, Including Hours

of Service for Commercial Drivers

2. EOBR to ELD (Electronic Logging Device)

3. Understand the Benefits of Utilizing ELD’s and Practical

Application/Integration into your Organization.

4. Realize the Value Proposition of ELD’s


Session Speakers

• Deborah Freund FMCSA

• Glenn Bramer Trimble

• Scott Vanselous TMW Systems

• Henry Prentice Noregon Systems

(Moderator)


Session Guidelines

• One Hour Session

• Presentations

• Questions & Discussion


Electronic Hours-of-Service Recording

Devices Rules: Past, Present, Future

Deborah M. Freund

Senior Transportation Specialist

Federal Motor Carrier Safety Administration


• History of legislation on HOS recording

• History of ELD and related rulemaking

• Highlights of Supplemental Notice of Proposed

Rulemaking (SNPRM)

• Next Steps

Outline of Today’s Presentation

6


• Truck and Bus Safety and Regulatory Reform Act (1988)

– Required Agency rules on electronic recorders ensure

that such devices not be used for driver harassment.

• HMTAA (1994)

– Required Agency HOS rules to specify “number, type, &

frequency” of supporting documents to be maintained.

• MAP-21 (2012)

– Required Secretary to adopt rules requiring CMVs

involved in interstate commerce and operated by drivers

required to keep RODS, be equipped with ELDs.

– Set deadline for prescribing regulations by Oct. 1, 2013.

Legislative Background

7


1988: AOBRD final rule

2000-2003: HOS NPRM proposed HOS recorders

for long-haul/regional carriers; final rule did not

include this provision

2004-2010: EOBR 1 rulemaking

February 2011: EOBR 2 NPRM

August 2011: EOBR 1 Final Rule vacated

2011-2012: MCSAC activity; listening sessions

February 2014: ELD SNPRM

Rulemaking History

8


April 5, 2010 Final Rule

• New performance-oriented standards for recorder technology.

• Mandatory use of recorders to remediate HOS non-compliance.

• Incentives promoting voluntary recorder use.

• Applicable to all motor carriers in interstate commerce

• Mandatory only for carriers subject to Remedial Directive on/after June 2012

9


February 2011 NPRM

• Drivers currently using RODS:

– Must use HOS recording devices;

– Would not have to maintain and retain certain

categories of HOS Supporting Documents.

• All motor carriers (RODS users and timecard

users) must maintain HOS management system

• Lead time: 3 years after publication of final rule.

10


Court Decision to Vacate

• Owner-Operator Independent Drivers

Association OOIDA filed suit in the Seventh

Circuit to invalidate 2010 final rule.

• In August 2011, the Court vacated the rule

based on FMCSA’s failure to address the

issue of driver harassment.

• For this reason, 2011 NPRM could no longer

rely on April 2010 technical specifications for

future ELD rulemaking.

11


Overview of SNPRM

Four primary components:

(1) Prescribes minimum technical standards for ELDs;

(2) Requires drivers who need to keep RODS to use ELDs,

per MAP-21 direction;

(3) Establishes explicit requirements for HOS supporting

documents, specifying the “number, type & frequency” in

accordance with statute;

(4) Prohibits harassment of drivers and establishes a

complaint process for drivers, due process for carriers, and

civil penalties.

12


Applicability

• MAP-21 (2012)

– Required Secretary to adopt rules requiring CMVs

involved in interstate commerce operated by drivers

required to keep RODS be equipped with ELDs.

• (Details to be added after SNPRM is published)


Timeline

• SNPRM published February xx, 2014

• 60-day comment period

• Comment analysis

• Development of final rule

– FMCSA, USDOT, OMB reviews

• Publication of final rule

• Implementation activities

• Compliance date


For more information …

Refer to Reg. ID No. 2126-AB20

FMCSA website: http://www.fmcsa.dot.gov

USDOT General Counsel – Significant

Rulemakings http://regs.dot.gov

Federal e-Rulemaking Portal:

http://www.regulations.gov

Federal Digital System:

http://www.gpo.gov/fdsys

http://www.fmcsa.dot.gov/

http://regs.dot.gov/

http://www.regulations.gov/

http://www.gpo.gov/fdsys


Electronic Logging Devices in Practice

Glenn Bramer

Marketing Director

Trimble Construction Logistics


Electronic Logging Devices

No Final Ruling yet, so

EVERYTHING is subject

to change

What we do know:

1. ELD Requirements from MAP-21

2. Who it applies to

3. Similar requirements in the European Union


ELD Requirements from MAP-21

Section 31137 (b)(1) – Electronic logging devices

(A)(i): to accurately record commercial driver

hours of service;

(A)(ii): to record the location of a commercial

motor vehicle;

(A)(iii): to be tamper resistant;

(A)(iv): to be synchronized to the operation

of the vehicle engine or be capable of

recognizing when the vehicle is being

operated;

(B): Allow law enforcement to access data

contained in the device during a

roadside inspection

• Needs to be able to manage current in-

force HOS rules

• GPS-enabled

• To ensure validity of collected data

• To automate collection of vehicle

operational data

• Data needs to be portable, and available

on-demand in the field


ELD Requirements from MAP-21

Section 31137 (b)(2) – Performance and Design

Standards (A) Defining standardize user interface to aid vehicle

operator compliance and law enforcement review

(B) Establishing a secure process for standardized

(i) and unique operator identification;

(ii) data access;

(iii) data transfer for vehicle operators between

motor vehicles

(iv) data storage for a motor carrier

(v) data transfer and transportability for law

enforcement officials

(C) Establishing a standard security level for an electronic

logging device and related components to be tamper

resistant by using a methodology endorsed by a

nationally recognized standards organization

(D) Identifying each driver subject to the hours of service

and record of duty status requirements under part 395

of title 49, Code of Federal Regulations

• Everyone will be required to conform to minimum usage

interface requirements

• Portability of data will be universal for all certified

Electronic Data Loggers

• Electronic Data Loggers will have to be ‘Tamper

Resistant’, conforming to a national standard

• Each driver will have a universally unique identifier


Similar solutions in EU

• In the European Union, digital tachographs became

mandatory as part of EU Regulation 1360/2002,

effective August 1, 2005

• Although similar in some respects to ELD, digital

tachograph requirements:

– Do not mandate recording location

– Do not have standardization regarding user interface

– Speed data is stored at 1-Hertz intervals, but not

stored on driver’s card

• Does require universally unique driver identification

in the form of a EU Driver’s License

• Requires motor carriers to report electronically both

vehicle usage hours and individual driver hours

• Requires data to be delivered to law enforcement

agencies by use of a special control card


ELD Value Proposition

Scott Vanselous

Chief Marketing Officer

TMW Systems


Obtaining Higher Value from ELD’s

• Integration with Maintenance Systems

– What is going on with the vehicle?

• Integration with Dispatch Systems

– Communications between Operations and

the Driver

• ELD’s – Electronic Logging Devices

– More features provide increased benefit

• Analytics

– Making sense of all the information

– take the right action at the right time

Incre

ased V

alu

e


The Value of ELD’s as standalone

• Increased data accuracy

• More hours to drive

• No paperwork, 15 1 min increment

• Less time at DMV Checkpoint

Automatic Capture of

hours

• GPS Positional data

• Speeding, Idling, Braking

• Tire Pressure Monitoring Systems

• Fault codes

Driver and Vehicle Insight

• Pre/Post Inspection Compliance

• Conformance to Inspection ProcesseDVIR’s


Integration with Dispatch Systems

• Planning to maximize hours remaining

• Increase driver satisfaction higher pay

• Increase asset utilization less idle time

Planning based on

available HOS

• Improve Driver behavior and performance

• Decrease out-of-route fleet tracking

• Early equipment diagnosticsIn-Route

• More accurate ETA’s

• Driver Confirmation Message

• Automatic alerts via Geodocding

Confirmation of Delivery


Integration with Maintenance Systems

• Improved equipment performance

• Early detection of potential failures

• Automatically schedule work to be done

• Increase asset utilization less down time

Fault code analysis

and remedy

• Automatically schedule work to be done

• Increase compliance higher CSA score

eDVIR’s


Analytics

• How did we perform to KPI’s

• What was planned versus what happened

• Factors involved (e.g. equipment failure, non compliance, …)

Operations Performance

• Identify best and worst performers

• Reduce speeding violations

• Productivity

Driver Behavior

• Predictive Maintenance reduce downtime

• Fuel Savings

• Fuel Tax

• Identify Cherries and Lemons in your fleet

Equipment Performance


ELD Value - Summary

• More than just Hours of Service (HOS)

• Higher Features = Higher Value

• Integrated with Operational Systems = Higher

Value

• Analytics Provide tremendous insight to:

– Driver Performance

– Equipment Utilization and Performance

– Compliance

– Safety


Questions / Discussion

• Deborah Freund – FMCSA

• Glenn Bramer – Trimble

• Scott Vanselous – TMW Systems

• Henry Prentice – Noregon Systems